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HomeMy WebLinkAboutDAQ-2025-0013311 DAQC-212-25 Site ID 10096 (B4) MEMORANDUM TO: STACK TEST FILE – SUNNYSIDE COGENERATION ASSOCIATES – EU #1 THROUGH: Harold Burge, Major Source Compliance Section Manager FROM: Robert Sirrine, Environmental Scientist DATE: February 25, 2025 SUBJECT: Source: Circulating Fluidized Bed Combustion Boiler (EU #1) Location: 1 Power Plant Road, Sunnyside, Carbon County, Utah Contact: Rusty Netz – 435-888-4476 ex107 Tester: Montrose Air Quality Services, LLC, Craig Kormylo 303-495-3936 FRS ID#: UT0000004900700030 Permit #: 700030005 dated March 8, 2023 Subject: Review of Pretest Protocol Dated February 18, 2025 On February 21, 2025, the Utah Division of Air Quality (DAQ) received a pretest protocol for emissions testing of the Sunnyside EU#1 located in Sunnyside, Carbon County, Utah. Testing will be performed August 5, 2025, and continue over a 30-day operating period to determine Hg emission rates and demonstrate continuing compliance with the MATS Hg LEE requirements found in 40 CFR 63 Subpart UUUUU and permit Conditions II.B.2.m(4) and (5), and II.B.2.m.1(c). PROTOCOL CONDITIONS: 1. RM 30B used to determine total vapor phase mercury emissions: OK 2. ALT -091 used to determine moisture content in lieu of RM4: OK DEVIATIONS: No deviations were noted. CONCLUSION: The protocol appears to be acceptable. RECOMMENDATION: Send attached protocol review and test date confirmation notice. ATTACHMENTS: Stack test protocol dated February 18, 2025 * - / $ - - $ ) ,* iuuth, DIVISION OF AIR OUALITY Sunnyside Cogeneration Associates P.O, Box t59 .Suunyside, Utah 84539 . (435) 888_4476 .Fax (435) 888-2538 February 18, 2025 Harold Burge Utah Divlsion of Air euality 195 North 1950 West Salt Lake Clty, Utah 8411G Subject:Protocol for Mercury Stack Testing to Demonstrate On-Going LEE status Sunnyslde Cogeneration Associates (SCA) Dear Mr. Burge: lncluded is SCA's Protocol for Mercury stack Testing to Demonstrate on-Going (LEE) status, TheHg testing pertains to the requirements of utility MAcr 40 cFR G3 subpart uuuuu. scA will continuewlth an annual 30'day Hg test to dernonstrate Low Emitting EGU status (LEE), The test will begin August5,2025. we look forward to working with you to comply with the requirements of this regulation. lf youhave any questions or concerns, please contact Rusty Netz or myself at (435) ggg-4476. Thank You, ,?lil,Q)t'it'6'(,. Michael trrlosley / Agent for Sunnyside Cogeneration Associates Rusty Netz - UTAH DFPARI MEXT-F- EJ-y!EON-ry1-F=NIAL Q UAL I rY DIVISION OF AIR OUALITY Source Test PIan for 2(J25 LEE Demonstration Unit EU#1 Sunnyside Cogeneration Associates Sunnyside, Utah Prepared For: Sunnyside Cogeneration Associates 1 Power Plant Road Sunnyside, Utah 84539 Prepared By: Montrose Air Quality Services, LLC 990 West 43rd Avenue Denver, CO 80211 For Submission To: Utah Division of Air Quality 195 North 1950 West Salt Lake City, UT 84116 Document Number: GPO43AS-O25822-PP-673 Proposed Test Date: August 5, 2lJ25 Submittal Date: July 5,2025 I certify that, to the best of my knowledge, the information contained in this document is complete and accurate and conforms to the requirements of the Montrose Quality Signature:Date: Title: 2/14/2O2s Name: Matthew Parks QA/QC Analyst I have reviewed, technically and editorially, details and other appropriate written materials contained herein. I hereby certify that to the best of my knowledge the presented material is authentic and accurate and conforms to the requirements of the Montrose Quality Management System and ASTM D7036-04. Signature: Name: Date: Title: 2/L4/202s Tim Wojtach Account Manager Table of Contents Section Paoe 1.0 Introduction,....... ...................5 1. 1 Summary of Test Program .... ... 5 t.2 Applicable Regulations and Emission Limits ....... 6 1.3 Key Personnel........... ..............7 2.0 Plant and Sampling Location Descriptions............. .........8 2.L Process Description, Operation, and Control Equipment........... .........8 2.2 Flue Gas Sampling Locations ............ I 2.3 Operating Conditions and Process Data...... .........9 2.4 Plant Safety............. ..........9 2.4.1 Safety Responsibilities ...............9 2.4.2 Safety Program and Requirements .........10 3.0 Sampling and Analytical Procedures .................12 3.1 Test Methods............ .......t2 3.1.1 EPA Method 308 ......... ..........12 3.2 Process Test Methods............ .........13 4.0 Quality Assurance and Reporting........... .................14 4.L QA Audits. ......L4 4,2 Quality Control Procedures ....14 4.2.1 Equipment Inspection and Maintenance .....L4 4.2.2 Audit Samples .......14 4.3 Data Analysis and Validation ...........14 4.4 Sample Identification and Custody .......15 4.5 Quality Statement ..........15 4.6 Reporting ...........15 4.6.1 Example Report Format .......16 4.6.2 Example Presentation of Test Resu|ts.............. .......17 List of Appendices Appendix A Supporting Information ......... ..........18 Appendix A.1 Units and Abbreviations ....19 Appendix A.2 Accreditation Information/Certifications ........ .......27 Appendix "S" Field Work Safety P1an......... .............29 List of Tables Table 1-1 Summary of Test Program and Proposed Schedule... ........ 5 Table 1-2 Reporting Units and Emission Limits ...............6 Table 1-3 Test Personnel and Responsibilities.... ...................8 Table 2-1 Sampling Location(s)......... ............ B Table 4-1 Example <Parameter> Emissions Results - Unit Name ........L7 List of Figures Figure 3-1 EPA Method 30B Sampling Train ....13 Figure 4-1 Typical Report Format .................16 1.O Introduction 1.1 Summary of Test Program Sunnyside Cogeneration Associates contracted Montrose Air Quality Services, LLC (Montrose) to perform an emissions test program at the Sunnyside Power Plant located near Sunnyside, Utah. The tests are conducted to determine compliance with the emission limits in 40 CFR Part 63, Subpart UUUUU. The specific objectives are to: . Perform annual mercury emissions testing on the exhaust stack of Unit EU#1 over a 30-day operating period . Conduct the test program with a focus on safety Montrose will provide the test personnel and the necessary equipment to measure emissions as outlined in this test plan. Facility personnel will provide the process and production data to be included in the final report. A summary of the test program and proposed schedule is presented in Table 1-1. Table 1-l Summary of Test m and Proposed Schedule To simplify this test plan, a list of Units and Abbreviations is included in Appendix A. Throughout this test plan, chemical nomenclature, acronyms, and reporting units are not defined. Please refer to the list for specific details. 1.2 Applicable Regulations and Emission Limits The results from this test program are presented in units consistent with those listed in the applicable regulations or requirements. The reporting units and emission limits are presented in Table 1-2. Table 1-2 Repofting Units and Emission Limits Unit EU#1 40 CFR Part 63, Subpart UUUUU (Low Emitting EGU Limit) 40 CFR Part 63, Subpart UUUUU (Low Emitting EGU Limit) 40 CFR Part 63, Subpart UUUUU (Low Emitting EGU Limit) A list of project participants is included below: Facility Information Source Location: 1.3 Key Personne! Project Contact: Role: Company: Telephone: Email: Agency Information Regulatory Agency: Agency Contact: Telephone: Email: Sunnyside Cogeneration Associates Sunnyside Power Plant 1 Power Plant Road Sunnyside, UT 84539 Rusty Netz Environmental Advisor Sunnyside Cogeneration Associates (435) 888-4476 x107 rusnetz@hotmail.com Utah Department of Air Quality Rob Leishman (801) s36-4438 RLeishman@utah.gov Testing Company Information Testing Firm: Montrose Air Quality Services, LLC Contact: Craig Kormylo Title: District Manager Telephone: (303) 495-3936 Email: CKormylo@montrose-env.com Table 1-3 details the roles and responsibilities of the test team. Table 1-3 Test Personnel and Responsibilities 2.O Plant and Sampling Location Descriptions 2.1 Process Description, Operation, and Control Equipment The Sunnyside Cogeneration Facility is a steam-electric Aenerating power plant located in Sunnyside, Carbon County, Utah. The plant consists of a circulating fluidized bed (CFB) combustion boiler designated EU #1, an emergency backup diesel-fired pump, diesel storage tanks, coal handling equipment, ash handling equipment and limestone handling equipment. EU #1 has a rating of 700 mmBtu/hrand is equipped with limestone injection and a baghouse for control of emissions. The EU #1 is fueled by coal refuse from the Sunnyside and Star Point Refuse Piles. The flylbottom ash generated from the coal combustion is disposed of in an on-site landfill or used for beneficial applications. 2.2 FIue Gas Sampling Locations Actual stack measurements, number of traverse points, and location of traverse points will be evaluated in the field as part of the test program, Table 2-1 presents the anticipated stack measurements and traverse points for the sampling locations listed. Table 2-l Sampling Location Sample location(s) are verified in the field to conform to EPA Method 1. Acceptable cyclonic flow conditions are confirmed priorto testing using EPA Method 1, Section 11.4. Operate mobile lab Facility interface, test crew coordination Execute stack platform responsibilities Preparation, support PM 2.3 Operating Conditions and Process Data Emission tests are performed while the source/units and air pollution control devices are operating at the conditions required by the applicable regulation. The units are tested when operating normally. Plant personnel are responsible for establishing the test conditions and collecting all applicable unit-operating data. Data collected includes the following parameters: . Relevant CEMS data 2.4 Plant Safety Montrose will comply with all safety requirements at the facility. The facility Client Sponsor, or designated point of contact, is responsible for ensuring routine compliance with plant entry, health, and safety requirements. The Client Sponsor has the authority to impose or waive facility restrictions. The Montrose test team leader has the authority to negotiate any deviations from the facility restrictions with the Client Sponsor. Any deviations must be documented. 2.4.L Safety Responsibilities Planning . Montrose must complete a field review with the Client Sponsor prior to the project date. The purpose of the review is to develop a scope of work that identifies the conditions, equipment, methods, and physical locations that will be utilized along with any policies or procedures that will affect our work . We must reach an agreement on the proper use of client emergency services and ensure that proper response personnel are available, as needed . The potential for chemical exposure and actions to be taken in case of exposure must be communicated to Montrose. This information must include expected concentrations of the chemicals and the equipment used to identify the substances. . Montrose will provide a list of equipment being brought to the site, if required by the client Project Day . Montrose personnel will arrive with the appropriate training and credentials for the activities they will be performing and the equipment that they will operate . Our team will meet daily to review the Project Scope, Job Hazard Assessment, and Work Permits. The Client Sponsor and Operations Team are invited to participate. . Montrose will provide equipment that can intefface with the client utilities previously identified in the planning phase and only work with equipment that our client has made ready and prepared for connection . We will follow client direction regarding driving safety, safe work permitting, staging of equipment, and other crafts or work in the area . As per 40 CFR Part 60 Subpaft A, Section 60.8, the facility must provide the following provisions at each sample location: o Sampling ports, which meet EPA minimum requirements for testing. The caps should be removed or be hand-tight. o Safe sampling platforms o Safe access to the platforms and test ports, including any scaffolding or man lifts o Sufficient utilities to perform all necessary testing . Montrose will use the client communication system, as directed, in case of plant or project emergency . Any adverse conditions, unplanned shutdowns or other deviations to the agreed scope and project plan must be reviewed with the Client Sponsor prior to continuing work. This will include any safe work permit and hazard assessment updates. Completion . Montrose personnel will report any process concerns, incidents or near misses to the Client Sponsor prior to leaving the site Montrose will clean up our work area to the same condition as it was prior to our arrival We will ensure that all utilities, connection points or equipment have been returned to the pre-project condition or as stated in the safe work permit. In addition, we will walk out the job completion with Operations and the Client Sponsor if required by the facility. 2.4.2 Safety Program and Requirements Montrose has a comprehensive health and safety program that satisfies State and Federal OSHA requirements. The program includes an Illness and Injury Prevention Program, site- specific safety meetings, and training in safety awareness and procedures. The basic elements include: All regulatory required policies/procedures and training for OSHA, EPA, FMCSA, and MSHA Medical monitoring, as necessary . Pre-test and daily toolbox meetings . Continued evaluation of work and potential hazards . Near-miss and incident reporting procedures as required by Montrose and the Client Montrose will provide standard PPE to employees. The PPE will include but is not limited to; hard hats, safety shoes, glasses with side shields or goggles, hearing protection, hand protections, and fall protection. In addition, our trailers are equipped with four gas detectors to ensure that workspace has no unexpected equipment leaks or other ambient hazards. The detailed Site Safety Plan for this project is attached to this test plan in Appendix "S". 3.O Sampling and Analytical Procedures 3.1 Test Methods The test methods forthis test program have been presented in Table 1-1. Additional information regarding specific applications or modifications to standard procedures is presented below. 3.1.1 EPA Method 3OB Determination of Total Vapor Phase Mercury Emissions from Coal-Fired Combustion Sources Using Carbon Sorbent Traps EPA Method 308 is a manual test method for measuring total vapor phase mercury (Hg) emissions from coal-fired combustion sources using sorbent trap sampling and an extractive or thermal analytical technique. The method includes sampling into duplicate sorbent traps, which are analyzed using a sorbent trap mercury analyzer. This type of analyzer uses thermal desorption with ultraviolet atomic absorption (UV AA) or ultraviolet atomic fluorescent (UV AF) cold vapor analysis. Each trap consists of two equal-mass sections of iodinated activated charcoal (Section 1 and 2). The results for Section 1 and Section 2 of each tube are reported in nanograms (ng) of Hg per section, and then they are summed. The charcoal sorbent is pre-checked to certify that mercury background levels are below the detection limit of the laboratory instrument. Each trap is uniquely numbered, and the sorbent batch number is printed on the outside of the glass tubes. One trap per run is pre- spiked in the first sorbent section with a known quantity of elemental mercury, using a proprietary gas-phase bulk spiking procedure. Each run includes two samples (A and B) collected concurrently from a single representative sampling point in the exhaust stack using a dual probe. Samples are drawn through the sorbent traps into a moisture knockout loaded with desiccant, and then through a sampling orifice. The typical sampling system is detailed in Figure 3-1. Figure 3-l EPA Method 3OB Sampling Train Spke Sorb€ni fTh.m@upl. Soruent Tr6p H..t.d \houm Lin. 3.2 Process Test Methods The applicable regulations do not require process samples to be collected during this test program. 4.O Quality Assurance and Reporting 4.1 QA Audits Montrose has instituted a rigorous QA/QC program for its air quality testing. Quality assurance audits are performed as part of the test program to ensure that the results are calculated using the highest quality data available. This program ensures that the emissions data we report are as accurate as possible. The procedures included in the cited reference methods are followed during preparation, sampling, calibration, and analysis. Montrose is responsible for preparation, calibration, and cleaning of the sampling apparatus. Montrose will also perform the sampling, sample recovery, storage, and shipping. Approved contract laboratories may perform some of the preparation and sample analyses, as needed. 4.2 Quality Control Procedures Montrose calibrates and maintains equipment as required by the methods performed and applicable regulatory guidance. Montrose follows internal procedures to prevent the use of malfunctioning or inoperable equipment in test programs. All equipment is operated by trained personnel. Any incidence of nonconforming work encountered during testing is reported and addressed through the corrective action system. 4,2.L Equipment fnspection and Maintenance Each piece of field equipment that requires calibration is assigned a unique identification number to allow tracking of its calibration history. All field equipment is visually inspected prior to testing and includes pre-test calibration checks as required by the test method or regulatory agency. 4.2.2 Audit Samples When required by the test method and available, Montrose obtains EPA TNI SSAS audit samples from an accredited provider for analysis along with the samples. Currently, the SSAS program has been suspended pending the availability of a second accredited audit sample provider. If the program is reinstated, the audit samples will be ordered. If required as part of the test program, the audit samples are stored, shipped, and analyzed along with the emissions samples collected during the test program. The audit sample results are reported along with the emissions sample results. 4.3 Data Analysis and Validation Montrose convefts the raw field, laboratory, and process data to reporting units consistent with the permit or subpart. Calculations are made using proprietary computer spreadsheets or data acquisition systems. One run of each test method is also verified using a separate example calculation. The example calculations are checked against the spreadsheet results and are inr^lr rderl in the final rennrt The "Standard Cnnditinnq" for this nrniprt are 7Q Q2 4.4 Sample Identification and Custody The on-site Field Project Manager will assume or assign the role of sample and data custodian until relinquishing custody. The sample custodian will follow proper custody procedures before departing from the test site including: . Assign the unique sample identification number to each sample . Attach sample labels and integrity seals to all samples . Complete COC form(s), ensuring that the sample identification numbers on the samples match the sample identification numbers on the COC . Pack and store samples in accordance with the test method requirements in appropriate transport containers for protection from breakage, contamination, or loss . Keep samples in a secure locked area if not in the direct presence of Montrose staff The sample custodian will follow proper custody procedures upon arriving at the Montrose office including: . Remove samples and COC documents from vehicles and check into designated secure sample holding areas . Store samples requiring additional measures such as refrigeration or dry ice appropriately 4.5 Quality Statement Montrose is qualified to conduct this test program and has established a quality management system that led to accreditation with ASTM Standard D7036-04 (Standard Practice for Competence of Air Emission Testing Bodies). Montrose participates in annual functional assessments for conformance with D7036-04 which are conducted by the American Association for Laboratory Accreditation (A2LA). All testing performed by Montrose is supervised on site by at least one Qualified Individual (QI) as defined in D7036-04 Section 8.3.2. Data quality objectives for estimating measurement uncertainty within the documented limits in the test methods are met by using approved test protocols for each project as defined in D7036-04 Sections 7.2,L and 12.10. Additional quality assurance information is included in the appendices. The content of this test plan is modeled after the EPA Emission Measurement Center Guideline Document (GD-042). 4.6 Reporting Montrose will prepare a final report to present the test data, calculations/equations, descriptions, and results. Prior to release by Montrose, each report is reviewed and ceftified 25 days of the completion of the field work. The report will include a series of appendices to present copies of the intermediate calculations and example calculations, raw field data, laboratory analysis data, process data, and equipment calibration data. 4.6.L Example Report Format The report is divided into various sections describing the different aspects of the source testing program. Figure 4-1 presents a typical Table of Contents for the final report. Figure 4-1 Typical Repoft Format Cover Page Certification of Repoft of Contents Section 1.0 Introduction 2.0 Plant and Sampling Location Descriptions 3.0 Sampling and Analytical Procedures 4.0 Test Discussion and Results 5.0 Internal QA/QC Activities Appendices A Field Data and Calculations B Facility Process Data C Laboratory Analysis Data D Quality Assurance/Quality Control E Regulatory Information 4.6.2 Example Presentation of Test Results Table 4-1 presents the typical tabular format that is used to summarize the results in the final source test report. Separate tables will outline the results for each target analyte and compare them to their respective emissions limits. Table 4-1 Example <Parameter> Emissions Results - Unit Name Date xx xx xx XX Tlme XX xx xx xx Process Data parameter 1, units XX xx xx XX parameter 2, units xx xx XX XX Sampling & Flue Gas Parameters sample duration, minutes xx xx xx xx Oz, o/o volume dry xx XX XX XX COz, o/o volume dry xx xx xx xx flue gas temperature, oF XX XX xx xx moisture content, o/o volume xx XX XX XX volumetric flow rate, dscfm xx XX xx XX <Parameter) ppmvd xx XX xx xx ppmvd @ 15o/o Oz xx xx xx XX lblhr xx XX XX xx tons/yr XX xx xx xx lb/MMBtu XX XX xx xx Appendix A Supporting Information Appendix A.1 Units and Abbreviations 66 ltgN,r+gp.H @x%02 lccl ldloc oF oR " Hzo 13.6 AH AP e pg P, Pw acfm,\ & Btu BE c8 Cers Coi, cf or fts cfm Gc", cM cm or m3 Cuo co cp cs CS cs cv D dcf dcm Dn Ds dsc'f dscfm dscm Fd fpm fps ft 42 UNlTS AND ABBREVIATIONS corrected to X% oxygen (conected for dilution air) absolute value of the confidence coefficient absolute value of the mean differences degrees Celsius degrees Fahrenheit degrees Rankine inches of water column specific gravity of mercury pressure drop across orifice meter, inches H2O velocity head of stack gas, inches H2O total sampling time, minutes microgram density of acetone, mg/ml density of water, 0.9982 g/ml or 0.002201 lb/ml actual cubic feet of gas per minute at stack conditions cross-sectional area of nozzle, ff cross-sectional area of stack, square feet (ft') British thermal unit proportion by volume of water vapor in gas stream particulate matter concentration in stack gas, gr/acf average unadjusted gas concentration, ppmv measured concentration of calibration gas, ppmv cubic feet cubic feet per minute average gas concentration adjusted for bias, ppmv average of initial and final system bias check responses from upscale calibration gas, ppmv cubic meters actual concentration of the upscale calibration gas, ppmv average of initial and final system bias check responses from lowlevel calibration gas, ppmv pitot tube coefficient particulate matter concentration in stack gas, gr/dscf calibration span, % or ppmv measured concentration of calibration gas, ppmv manufactured certified concentration of calibration gas, ppmv drift assessment, % of span dry cubic feet dry cubic meters diameter of nozzle, inches diameter of stack, inches dry standard cubic feet dry standard cubic feet per minute dry standard cubic meters F-factor, dscf/MMBtu of heat input feet per minute feet per second feet ear rara faal 60 l$?N,T+gp.H I in k K K3 & kg Kp kwscfh I lb/hr lb/MMBtu lpm m M m' m8 Md meq mg Mg min ml or mL mm MM MMBtu/hr mn mol mol. wt. or MW MS MW n ng nm oI bar ps Ps P, ppb ppbv ppbvd ppm ppmv ppmvd ppmvw Ps psi psia psig P.,, UNITS AND ABBREVIATIONS percent of isokinetic sampling inch kilo or thousand (metric units, multiply by t031 kelvin (temperature) conversion factor 0.0154 gr/mg conversion factor 0.002668 ((in. HgXftr))/((mlX'R)) kilogram pitot tube constant (85.49 fVsec) thousand wet standard cubic feet per hour liters pounds per hour pounds per million Btu liters per minute meter or milli thousand (English units) or mega (million, metric units) cubic meters mass of residue of acetone after evaporation, mg molecular weight of stack gas; dry basis, lb/lb-mole milliequivalent milligram megagram (106 grams) minute milliliter millimeter million (English units) million Btu per hour total amount of particulate matter collected, mg mole molecular weight molecular weight of stack gas; wet basis, lb/lb-mole molecular weight or megawatt number of data points nanogram nanometer barometric pressure, inches Hg picogram stack static pressure, inches H2O barometric pressure of dry gas meter, inches Hg parts per billion parts per billion, by volume parts per billion by volume, dry basis parts per million parts per million, by volume parts per million by volume, dry basis parts per million by volume, wet basis absolute stack gas pressure, inches Hg pounds per square inch pounds per square inch absolute pounds per square inch gauge standard absolute oressure. 29.92 inches Ho 64\ f+?N,I+gLH SBnn"t SB, scf sclh scfm scm scmh sec sf, sq. ft., or ft2 std t T o.szs Ta Tm ton or t tph or tons/hr tpy or tons/yr T" T.,o va Vt. Vmlstol vm vs Vrc(sto) Vwilstol Vmg(sto) W wa Wr.p Wss UNITS AND ABBREVIATIONS post-run system bias check, % of span pre-run system bias check, % of span standard cubic feet standard cubic feet per hour standard cubic feet per minute standard cubic meters standard cubic meters per hour second square feet standard metric ton (1000 kg) t-value absolute average ambient temperature, oR (+459.67 for English) absolute average dry gas meter temperature, oR (+459.67 for English) ton = 2000 pounds tons per hour tons per year absolute average stack gas meter temperature, oR (+459.67 for English) absolute temperature at standard conditions volt volume of acetone blank, ml volume of acetone used in wash, ml total volume H2O collected in impingers and silica gel, grams volume of gas sampled through dry gas meter, ftJ volume of gas measured by the dry gas meter, corrected to standard conditions, dscf stack gas volume sampled, acf volume collected at stack conditions through nozzle, acf average stack gas velocity, feet per second volume of water vapor condensed, corrected to standard conditions, scf volume of water vapor in gas sampled from impingers, scf volume of water vapor in gas sampled from silica gel, scf watt weight of residue in acetone wash, mg total weight of impingers, grams total weight of silica gel, grams dry gas meter calibration factor, dimensionless 66 l+?.N,r+gLH AAS ACDP ACE AD ADL AETB AS ASTM BACT BDL BHP BIF BLS cc CD CE CEM CEMS CERMS CET CFR CGA CHNOS CNCG CO coc COMS CPM CPMS CT CTM CTO CVAAS D6 DE Dioxins DLL DNCG ECD EIT ELCD EMPC EPA EPRI ES ESP EU FCCU FGD FI FIA FID FPD trPtr, ACRONYMS atomic absorption spectroscopy air contaminant discharge permit analyzer calibration error, percent of span absolute difference above detection limit Air Emissions Testing Body applicable standard (emission limit) American Society For Testing And Materials best achievable control technology below detection limit brake horsepower boiler and industrial furnace black liquor solids confidence coefficient calibration drift calibration error continuous emissions monitor continuous emissions monitoring system continuous emissions rate monitoring system calibration error test Code of Federal Regulations cylinder gas audit elemental analysis for determination of C, H, N, O, and S content in fuels concentrated non-condensable gas catalytic oxidizer chain of custody continuous opacity monitoring system condensible particulate matter continuous parameter monitoring system combustion turbine conditional test method catalytic thermal oxidizer cold vapor atomic absorption spectroscopy equivalent diameter destruction efliciency polychlorinated dibenzo-p-dioxins (pcdd's) detection level limited dilute non-condensable gas electron capture detector Engineer ln Training electoconductivity detector (hall detector) estimated maximum possible concentration US Environmental Protection Agency Electric Power Research lnstitute emission standard (applicable limit) electrostatic precipitator emission unit fluid catalytic cracking unit fl ue gas desulfurization flame ionization fl ame ionization analyzer flame ionization detector fl ame photometric detector filfarehla narlinr rlato mattor 6/.} I+?N,I+ST.H GC/MS GFAAS GFC GHG HAP HC HHV HPLC HRGC/HRMS HRSG IC ICAP ICPCR ICP.MS IR rso KW LFG LHV LPG MACT MDI MDL MNOC MRL MS NA NCASI NCG ND NDIR NESHAP NG NIOSH NIST NMC NMOC NMVOC NPD NSPS OSHA PAH PCB PCWP PE PFAS PI PID PM PMro PMz.s POM t? ACRONYMS gas chromatography/mass spectroscopy graphite furnace atomic absorption spectroscopy gas filter correlation greenhouse gas hazardous air pollutant hydrocarbons higher heating value high performance liquid chromatography high-resolution gas chromatography/high-resolution mass spectroscopy heat recovery steam generator ion chromatography inductively-coupled argon plasmography ion chromatography with a post-column reactor inductively coupled plasma-mass spectroscopy infrared radiation lnternational Standards Organization kilowatts landfill gas lower heating value liquified petroleum gas maximum achievable control technology methylene diphyenyl diisocyanate method detection limit maximum normal operating conditions method reporting limit mass spectrometry not applicable or not available National Council For Air And Steam lmprovement non-condensable gases not detected non-dispersive infrared National Emissions Standards For Hazardous Air Pollutants natural gas National lnstitute For Occupational Safety And Health National lnstitute Of Standards And Technology non-methane cutter non-methane organic compounds non-methane volatile organic compounds nitrogen phosphorus detector New Source Performance Standards Occupational Safety And Health Administration polycyclic aromatic hydrocarbons polychlorinated biphenyl compounds plywood and composite wood products Professional Engineer per- and polyfluoroalkyl substances (PFAS) photoionization photoionization detector particulate matter particulate matter less than 10 microns in aerodynamic diameter particulate matter less than 2.5 microns in aerodynamic diameter polycyclic organic matter performance specifi cation 60 l*?N,r+gp.I OA/OC QI QSTI RA RAA RACT RATA RCTO RICE RM RTO SAM SCD SCR SD Semi-VOST SRM TAP TBD TCA TCD TGNENMOC TGNMOC TGOC THC Ttc TO TO TPM TSP TTE ULSD UV VE voc VOST WC WWTP ACRONYMS quality assurance and quality control Qualified lndividual Qualifi ed Source Testing lndividual relative accuracy relative accuracy audit reasonably available control technology relative accuracy test audit rotary concentrator thermal oxidizer stationary reciprocating internal combustion engine reference method regenerative thermal oxidizer sulfuric acid mist sulfur chemiluminescent detector selective catalytic reduction system standard deviation semivolatile organic compounds sample train standard reference material toxic air pollutant to be determined thermal conductivity analyzer thermal conductivity detector total gaseous non-ethane non-methane organic compounds total gaseous non-methane organic compounds total gaseous organic compounds total hydrocarbons tentatively identified compound thermal oxidizer toxic organic (as in EPA Method TO-15) total particulate matter total suspended particulate matter temporary total enclosure ultra-low sulfur diesel ultraviolet radiation range visible emissions volatile organic compounds volatile organic sample train water column waste water treatment plant 66 l+gN,T+gp.H CHEMICAL NOMENGLATURE Ag As Ba silver arsenic barium Be beryllium C carbonCd cadmiumCdS cadmium sutfide CH2O formaldehyde CH3CHO acetaldehyde CH3OH methanol CHr methane C2H4O ethylene oxide CzHo ethane CaH4O acrolein CaH6O propionaldehyde CsHg propane C6HsOH phenol ClO2 chlorine dioxide CO carbon monoxideCo cobalt COz carbon dioxide Cr chromiumCu copperEtO ethylene oideEIOH ethyl alcohol (ethanol) hydrogen water flzOz hydrogen peroxide HzS hydrogen sulfide H2SO4 sulfuric acid HCI hydrogen chlorideHg mercuryIPA isopropyl alcoholMDI methylene diphyenyl diisocyanate MeCl2 methylene chloride MEK methyl ethy'l ketoneMeOH methanolMn manganese nitrogen ammonia nickel nitric oxide nitrogen dioxide nitrogen oxides orygenP phosphorusPb leadPCDD polychlorinated dibenzo-p{ioxins Se Soz Sos SO, TCDD TCDF TGOC THC TI TRS Zn selenium sulfur dioxide sulfur trioxide sulfur oxides tetrachlorodibenzodioxi n tetrachlorod ibenzof u ran total gaseous organic concentration total hydrocarbons thallium total reduced sulfur compounds zinc Clz H2 Hzo N2 NHs Ni NO Noz NO, o2 Appendix A.2 Accreditation Informatio n / Certifications (n\to@No)o)oo-o\ \oOtIo-cIlnNt)o q)q)bOPLoboa)F(tO!)L]Nq)Lq) \313q) \3oc6BLhooa.o\JLq)d%FFr oU.Eq) <r )c= .e E - E B3 x ?9 S R s/ t- (f ) ;- o -c o 6= EN <y 9 > .f i k o C0 ) J J o hz - d .9 6 o ) ( ) 6< E : ^- o .9 -) l (l ) * 1 - . : l .9 X 6E >L t s O > oFU'_- c PE?o (J ar o OE . q r OD € -e g !5 s , ! o. = 9. s 6 O -F qo c <' E O P; E .! o cE3 : -v . E ( o; = oo u 52 t] 9L E hP a < e& Nn E <; o =o U .! o - o= o PE T * o' = b8 H F. : r E .Y >- br b X =o o L^ LoX o oE 6 iE s o- o rl ; C! g ns o Yo e Eh E a= -'E ar ) !o < =EE, d ()Ec arqUlr {&rqaHF{ l. l )cilF{ rqao&Hzc oo=oG)oooo-cJ(\ { co+o*Dq)oor_o+.ol_oaoJo(Lc.9t.9oov, .4co(_ )r-oE tosh0 -\o; l *)a .q )H.r t \oo; )aca o; )dLFXLop ) \Sq)+) ot ) \3pLq)q) -a gE +C. loN-of-ooLLooo5Nc\ .q-c .Drq)coC) o_ Appendix *S" Field Work Safety Plan MI+gN,T+g[H SITE SAFETY PLAN BOOKLET Client Project Manager: ,arrMLJNlRL))t Site Safety Purpose Page 1 of 2 Plan and JHA Purpose and lnstructions Employee safety is the top priority of Montrose Environmental Group. All employees must be trained to assess and mitigate hazards. The District Manager and Project Manager are responsible to ensure all hazards have been properly identified and managed. All employees have Stop Work Authority in all situations where an employee feels they or their co-worker cannot perform a job safely or if there is a task for which they have not been adequately trained. The Site Safety Plan (SSP) has been developed to help assist Montrose test crews with identifying physical and health hazards and determining how the hazards will be managed. Additionally, the SSP will help each crew manage the safety of the employees by providing emergency procedures and information. The booklet contains a several safety forms that may be required in the field. lnstructions The SSP consists of the following: 1. A Pre-Mobilization Test Plan - To be completed in it's entirety by the client project Manager prior to the test. 2. A Job Hazard Analysis is a standardized, two-page, fillable form that is used to evaluated the tasUsite's particular hazards and controls. The form also includes a daily toolbox topic and daily hazard review with sign off by the team. The client Project Manager is responsible to complete the JHA form through section 8. Upon arrival at the test site, the team will review the form for accuracy, making any corrections requiied and complete the remainder of the JHA. Section 9 will require at least three tasks, hazards and controls be identified for the project. Each team member has the option to discuss making changes or adding to the JHA and must sign on the Job Hazard Analysis form in agreement and sign in Section 10. The JHA is to be modified when conditions change. A toolbox meeting with a daily topic in addition to a review of the hazard analysis is required daily for the duration of the test. An additional sheet of paper with the toolbox topic and signatures can be added to the SSP packet. 3. Hazard Control Matrix - contains useful information on both engineering and administrative controls that a crew can use to reduce or eliminate the hazards they have observed plus applicable PPE that may be required. 4. Emergency Action Plan - The Job Supervisor/ Client Project Manager (CPM) will complete the Emergency Action Plan form and ensure that all employees are familiar with the facility emergency and evacuation procedures, assembly/ rally points, alert systems, and signals prior to work commencing. ln the event of an emergency situation/ evacuation, the Job Supervisor/ CPM will maintain a roster and be responsible for accounting for all employees. The Job Supervisor/ CPM will ensure that this Emergency Action Plan Form is completed, communicated to all employees, signed, and posted. 5. Additional Forms, as applicable 6A MON I RUSE Page2 of 2 Site Safety Plan and JHA Purpose and lnstructions The SSP is a living document. The Project Manager should continually update their SSPs as new information and conditions change or if new hazards are presented. Each completed SSP should be maintained with the Test Plan in the office for a period of 3 years. There will be an audit process developed for the Site Safety Plans. ry \,vtL)N I RL))I PRE.MOBILIZATION TEST INFORMATION Page 1 of2 PROJECT NAM E/LOCATION : TEST DATE: PROJECT #: PROJECT MANAGER: TEST SCOPE: SITE CONTACT: Name:Contact Phone: Source Tvpe: New Source: _ Revisit: _ Coal Fired Electric Utility: _ Ethanol Plant: _ Prj#/Dateffech: ChemicalMfg. of CemenULime Kiln Plant: _ Specialty Mfg. of:Other: Anticipated Effluent Composition - check all that apply and fill in expected concentration in ppm/% tr VOC tr co Engineering Controls to be lmplemented: tr NOx tr other lf other, explain: Flammable:Toxic:Dust: tr SOz Corrosive: Additional Safety Equipment Required: Personal gas monitors: _ Respiratory Protection : Half Face_ Full Face_ HEPA Filters_ Supplied Air: _ (Safety Dept. Approval) Approximate Flue Gas Temperatures, (F) below 210 210 to 450 450 to 950 above 950 other lf other, explain: Approximate Duct Pressure, (iwg): tr above tr other tr below tr +3 to +7 lf nther cvnlain' -3 to +3 +7 rfv r Nlt)N ll(L))t Sampling Location: Stack Port _ Approximate Sampling Platform Height, (ft) PRE.MOBILIZATION TEST INFORMATION Page 2 of 2 Duct Port tr below 6 lf other, explain: tr other Other: trtrtr 6 to 50 50 to 100 above 100 Access and Protection: Elevators: _ Ladders: _ MEWP Lift: _ Scaffold: _ Equipment Hoist: _ Guardrails: _ Toe plate: _ Engineered Tie Off Points: _ Heat Shield: _ Describe how equipment will be mobilized to the sampling location: Additional lnformation : Effluent Chemical Requlatorv Limits Gas Name Chemical Formula Cal OSHA PELI (ppm) Cal OSHA STEL2(ooml NIOSH REL TWA3 (ppm) Cal OSHA Geiling (oom) tDLH. (ppm) 3arbon Monoxide co 25 200 35 200 1,200 Nitric Oxide NO,25 ND5 25 ND 100 Sulfur Dioxide SOz 2 5 2 ND 100 Hvdrooen Chloride HCt 0.3 2 ND 2 50 Hydrogen Sulfide HzS 10 15 10 (10 min.)c 50 100 )alifomia Occupational Safety and Health Administration (OSHA) Permissible Exposure Linit (PEL) based on an ?-hour shift; 2: Cal OSHA Short-term Exposure Limit (STEL) based on a 11-minute period; 3: National lnstitute for Occupational Safety and Health (NIOSH) Recommended Exposure Limit (REL) Time-weighted Average (TWA) based on an 8-hour shift; 4: lmmediately Dangerous to Life or Health (IDLH); 5: Not Defined (ND); C: Ceiling Limit - Maximum allowable human exposure limit for an aitbome or gaseous subslanco, which is not to be exceeded, even momentarily. ta{\ fv.-l()N I KL)}1 Job Hazard Analysis Error Rlgk E Time Pressure E Remote Work Location E > 12 hr shift ! working > 8 consecutive days E Lad of procedures E Extreme temps, wind >30mph E Personal illnesslfatigue E Vague work guidance E Monotonous Activity E first day back aftertime off E ttuttipteioO locations E other: Physical Hazards Hazard Controls Dust Hazards i E Dust Mask I Goggles E otner Thermal Bum i E xot Gloves E Heat Shields E other P;6iir" clothins' -Electrical Hazards i E Connections Protected from Elements I External GFCI E Otfril E Xe nating Requirement E lntrinsically Safe Requirement lnadequate Lighting ! E tnstatt Temporary Lighting E Headlamps Slip and Trip i E Housekeeping E Barricade Area E Other: Hand Protection i El Cut Resistant Gloves E pinch Pts. E General E ebctrical ! lmpaa Resistant E other: Potential Hazards for Consideration Secondary Permits i E not Work trl Confined Space f] Excavation Wo*ing from Heights i E f"tting objects ! Fdl protection E Drop zone protection E] ptatform load ratings see alro Sect.7 ! ! ScanotO inspection E Laoder inspection E Barricades for equipment Electrical i E gxposeO wire/connector E Verify equipment groundinS E Arc Flash Lifting i E Crane lift plan fl Rigging inspection E fag lines used E Hoists in place Respiratory i E Unexpected exposure E Chemical E Dust (combustible) E PEL provided E cra.i ! Gas detection equiSee also Sect. 8 : U Cartridqes or supplied air available 1of 3 1. 2. 3. 4. llient lontact Name Date =acilitv SSP Writer PM 3lient Rep I Job Preparation ! .too Site Walk Through completed tr I Sate Work Permit Received from Client _J Site Specific Training Complete lf the heat index is expected to be above 91", fill out the Heat Stress Prevention Form. acility lnformation/Emergency Preparedness lf non+mergency medical attention is needed, call: AXIOM #: 877-502-9466. Plant Emergency # EMS Location Certified First Aid Person: Evacuation Routes Rally Point Severe Weather Shelter Location Eye Wash & Safety Shower Location EYes ENo Source lnformation: (list type): Stack Gas Temp. ("F) Stack Gas Press. ("HrO) Stack Gas Components: Stack Gas lnhalation Potential? EYes E No tf ves. see List of Hazard Chemacats. lPanrrirar{ FDF l-'l Ft a rd t{ af c l-'l Safahr Glaeeaq J-'l Safphr Tno Shoc/Rnnt l-'l l'.lcarinn Pr^ta^ti^n l-lSafot., SnntfarB /a" \ MtJN I,RU-\t Additional Work Place Hazards Job Hazard Analysis 2of3 ritical Procedures - check all that apply - *indicates additional form must be completed or collected from client E Heat Stress Prevention* E Confined Space' El MEWP' E Roof Work E Scattoto E CotO Weather Work ! Hazardous Energy Controt- E Exposure Monitoring E Other: 7.From Heights Fall Protection i! Fixed Guardrails/Toe boards E] fatt Prevention PPE Warning Line System Falling Objects Protection ! E aartcaaing El Uetting fl House Keeping ! Tethered Tools El Catcn Blanket or Tarp Fall Hazard Communication i E Adjacenuoverhead Workers E Contractor Contact E Client Contact 8.Other Consideratione Environmental Hazards - Weather Forecast E HeaUCotd Eltigntning E Rain E Snow I lce E Tornado ! Wind Speed Steps for Mitigation: Electrlcal Safety Planning Plant Hook up: E t tov E 22ot24ov E +aov E Generator E Hard wired into panel Electrical Classified Area: fJYes fl No Trailer Grounded: E yes E f'lo Plug Type Electrical Hook Up Responsibility: List of Hazardous Chemicals E Acetone E Nitric Acid E Hydrog"n Peroxide I compressed Gases fl Hexane E Suffiuric Acid E lsopropyl Alcohol I Flammable Gas E Toluene E Hydrochloric Acid f] liquio Nitrogen ! Non-Flammable Gas E nzs E Carbon Monoxide Steps for Mitigation: lildlife/Fauna in Area ! Poison lvy I Poison oak Elnsects:IWildlife: Personnel w/ known allergies to bees stings or other allergens? [ Yes Euo 1 2 3 't 2 3 1 2 3 1 2 3 1 2 3 1 2 3 Hazards and Mitigation Hazard(s)Mitigation ,a".MLJNlKL),-\t Job Hazard Analysis 3of3 JHA REVIEW: Crew Names & Signatures Printed Name Signature Date Printed Name Sisnature Date JHA Meetinq & Review Items to revlew: o Change in conditions o Extended work hours r Daily Safety Topic o New workers or contractors r Occunence of near misses or injuries lnitialing demonstrates that site conditions and hazards have not changed from the original SSP. lf changes did occur, make the necessary updates to this JHA and add notes as applicable in Section 9. Day Diecuselon Toplc lnltlalr 2 3 4 5 6 7 I I 10 11 rf,, r i'vl(/r\ i lr( )\l Poge 1 of 2 EMERGENCY ACTION PLAN FORM The Job Supervisor/ Client Project Manager (CPM) will ensure that all employees are familiar with the facility emergency and evacuation procedures, assembly/ rally points, alert systoms, and signals prior to work commencing. ln the event of an emergency situation/ evacuation, the Job Supervisor/ CPM will maintain a roster and be responsible for accounting for all employees. The Job Supervisor/ CPM will ensuro that this Emergency Action Plan Form is completed, communicated to all employees, and posted. .You must follow the client's emergency action plan fir6t, and notify your Supervisor immediately. .lf incident is life threatening, CALL 911 IMMEDIATELLY .lf non-emergency medical attention is needed, call N(IOM Medical number: 877-502-9466. 1 MEG Job Supervisor/ CPM's Name: 2 MEG Job Supervisor/ GPM's Telephone Number: 3 MEG Job Safety Supervisor (if applicable): 4 MEG Job Safety Supervisor's Telephone Number: 5 Plant's Emergency Telephone Number: 6 Local Hospital/ Clinic Telephone Number: 7 Emergency Ops Radio Ghannel: 8 PIant's #1 Contact Person's Name: 9 Plant's #1 Contact Person's Telephone Number: 10 Plant's #2 Contact Person's Name: 11 Plant's #2 Contact Person's Telephone Number: 12 Designated Assembly Point Location: 13 Evacuation Routes: 14 Severe Weather Shelter Location: 15 Eye Wash and Safety Shower Location: ,a",Mt]NIRU)t Page 2 of 2 EMERGENCY EVACUATION AND ASSEMBLY MAP Facility Name: CHEMICAUGAS: ; SHELTER.IN-PUCE: : Shelter(s) Description: Assembly Point(s) Description: EMERGENCY ACTION PLAN FORM AND EVACUATION ASSEMBTY MAP REVIEW: Crew Names and Signatures [viNlLri\iK\)\t Page 1 of 1 Daily MEWP Lift lnspection Form All checks must be completed prior to each work shift, before operation of the MEWP lift. This checklist must be used atthe beginning of each shift or following 6 to 8 hours of use. MEWP Lift Model #:Serial Number: Make:Rented or Owned: r Check "Yes" if an item is adequate, operational, and safe.. Check "No" to indicate that a repair or other corrective action is required prior to use.. Check "N/A" to indicate "Not Applicable." Items to be lnspected 1. All MEWP lift components are in working condition (i.e. no loose or missing parts, torn orloose hoses, etc.) - if something can be easily loosened by hand then it is not sufficient. 2. Hydraulic fluid level is sufficient, with the platform fully lowered 3. Hydraulic system pressure (see manufacturer specs) is acceptable. lf the pressure is low, determine cause and repair in accordance with accepted procedures as outlined in service manual. 4. Tires and wheel lug nuts (for tightness) 5. Hoses and cables (i.e. worn areas or chafing) 6. Platform rails and safety gate (no damage present) 7. Pivot pins secure 8. Welds are not cracked and structural members are not bent or broken 9. Warning and instructional labels are legible and secure, and load capacity is clearly marked. 10. Manufacturer's lnstruction Manual is present inside the bucket 11. Base controls (switches and push buttons) can be properly operated 12. Platform conditions are safe (i.e. not slippery) 13. Fire extinguisher is present, mounted and fully charged, located inside the bucket 14. Headlights, safety strobe light and back-up alarm are functional 15. Workplace is free of hazards (overhead powerlines, obstructions, level surface, high winds, etc.)'Do not operate if winds are 20 mph, unless otherwise specified by manufacturer recommendations. Yes tr tr tr tr n tr tr tr tr tr tr tr tr tr tr N/A tr tr tr tr tr tr tr tr tr tr tr tr tr tr ! No tr n tr tr ! n tr tr tr tr n n tr tr n Operator Name & Signature Location Harness lnspections: LocationGround Control Name & Signature 6n- yo N TROSE Page 1 of 1 Extended Hours Safety Audit Project Number:Date:Time: When a project is expected to extend past a 14-hour work day, this form must be completed to evaluate the condition of the crew, and the safety of the work environment. Permission to proceed into extended work hours must come from a District Manager (DM) or Regional Vice President (RVP). Technical RVPs can authorize moving forward, if they are in the field or if they are managing the project. 1. Hold test crew meetinq Test crew initials: . Temperature and weather o Hoisting. Lighting . PPE (i.e. respirators, etc.)o Working from Heights r Pollutant concentration in ambient air (SOz, HzS, ect.) Notifv DM or RVP The PM must contact either the DM or RVP to discuss the safety issues that may arise due to the extended work period. lf the DM is the acting PM on the job site, they must contact the RVP. During this time, they can come to an agreement on how to proceed. ltemsto discuss include: a a I a Reason for extended hours Reason for delay Production limitations lmpending Weather Contact the client The PM, DM or RVP must discuss with client any identified safety concerns, the client's needs and mutually agree on how to proceed. Discussion should also include the appropriate rest period needed before the next day's work shift can begin. The DM and/or a RVP must be informed on the finaldecision. 2. 3. The test leader should look for signs of the following in their crews: r lrritability. Lack of motivation. Headacheso Giddiness . Fatigue. Depression. Reduced alertness, lack of concentration and memory The test leader should assess the environmental and hazardous concerns: FinalOutcome: 1. 2. /ar\ MLJN I RU)t Page 1 of 1 Heat Stress Prevention Form This form is to be used when the Expected Heat lndex is above 91' F, and is to be kept with project documentation. Proiect Manaqer (PM):Exoected Hioh Temo: Date(s):Expected Heat lndex: Review the signs of Heat Exhaustion and Heat Stroke lf Heat lndex is above 91" F:r Provide cold water and/or sports drinks to allfield staff (avoid caffeinated drinks and energy drinks which can increase core temperature). o Bring no less than one gallon of water per employee. lf employee(s) are dehydrated, on blood pressure medication or not acclimated to heat, ensure they are aware of the heightened risk for heat illness. Provide cool head bands/vests/etc.o Have ice available to employees. lmplement work shift rotations and breaks, particularly for employees working in direct sunlight.. Provide as much shade at the jobsite as possible, including tarps, tents or other acceptable temporary structures.r PM should interview each field staff periodically to evaluate for signs of heat illness lf Heat lndex is above 103" F:. Employees must stop for drinks and breaks every hour (about 4 cups/hour). Employees are not permitted to work alone for more than one hour at a time without a break offering shade and drinks. Employees should wear cool bands and vests if working outside more than one hour at a timeo PM should interview each field staff every 2 hours to evaluate for signs of heat illness 3. ;, Cel, p.le, 6 clammy rkln / Nausa orwmlting ffi Nausa or rcmltint R.pid,wakpul* - Rapid,stronSpul* Musctecnmps II Mayto*(i') UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF AIR OIJALITY This is the Last Page of This Document If you have any questions, please contact one of the following individuals by email or phone. Name: Craig Kormylo Title: District Manager Region: USA - Stack - Great Plains - Operations Email : CKormylo@montrose-env.com Phone: (303) 495-3936 Name: Glen Capra Title: Vice President Region: USA - Stack Email : GCapra@montrose-env.com Phone: (5L2) 772-6450